Last updated: 2026-05-01
Privacy Policy
Pragma Digital Labs S.L. ("Pragma", "we") respects the privacy of visitors to pragmadigitallabs.com. This policy explains what data we collect, why, how long we keep it, and how to exercise your rights under the EU General Data Protection Regulation (GDPR) and Spanish data-protection law (LOPDGDD).
1. Data controller
Pragma Digital Labs S.L., a company registered in Spain. Contact: info@pragma-dl.com.
2. What we collect
When you submit the contact form (Request a Scope Review) we collect: your name, work email, organisation name, project context, and timeline. When you email us directly, we collect what's in the email body.
We do not use cookies for tracking. The site uses Vercel Analytics, which is cookieless and does not identify individual visitors. We do not run third-party advertising trackers.
3. How we use it
Contact-form submissions are used solely to respond to your inquiry: assess fit for a Scope Review, prepare a written proposal, or schedule an introductory call.
Email correspondence is used for the project-engagement lifecycle: scope discussion, proposal delivery, contract negotiation, project execution, and post-engagement follow-up.
4. Legal basis (GDPR Art. 6)
Article 6(1)(b) — performance of a contract or steps taken at your request prior to entering into a contract (the Scope Review process).
Article 6(1)(f) — legitimate interest in maintaining a record of past project communications for client-relationship continuity.
5. Where data goes
The site is hosted on Vercel (Vercel Inc., USA — Standard Contractual Clauses in place). Form submissions are stored in our internal CRM (Odoo, self-hosted in Spain). Email correspondence is stored in Pragma's email infrastructure.
We do not sell, rent, or share data with third parties for marketing purposes.
6. Retention
Contact-form submissions: 24 months from last contact, unless an active engagement extends the period.
Engagement-related correspondence: duration of the engagement plus 7 years for tax/accounting compliance (Spanish law).
After the retention period, data is deleted or anonymised.
7. Your rights
Under GDPR you have the right to: access your data, correct it, request erasure, restrict processing, and data portability. To exercise any of these, email info@pragma-dl.com with a brief description of the request. We respond within 30 days.
You also have the right to lodge a complaint with the Spanish Data Protection Authority (Agencia Española de Protección de Datos, www.aepd.es).
8. Updates
We may update this policy. The "Last updated" date at the top reflects the most recent revision. Material changes will be communicated via the homepage banner or direct email to active engagement contacts.